ML20126K884

Forwards Proprietary Version of Tables 1 & 2 Re Facility Turbines Wheels W/Keyway Ultrasonic Indications.Includes Explanation of Nuclear Wheel Info.Tables Withheld (Ref 10CFR2.790)

ML20126K884
Person / Time
Site:	Dresden, Quad Cities
Issue date:	05/18/1981
From:	Timo D GENERAL ELECTRIC CO.
To:	Ippolito T Office of Nuclear Reactor Regulation
Shared Package
ML19262F425	List: ML20126K884
References
NUDOCS 8105220361
Download: ML20126K884 (8)

Text

3- .) x GEN ER AL h ELECTRIC TURBINE OPERATIONS GENERAL ELECTRIC COMPANY .. . . SCHENECTADY, NEW YORK 12345 Phone (518) 385-2211 et x

[- b May 18,1981 Mr. T.A. Ippolito, Chief Operatir,g Reactors-Branch 2 , ,

Division of Operating Reactors g U.S. Nuclear Regulatory Connision ( g- /

Washington, DC 20555

SUBJECT:

Turbine Wheel (Disc) Information for Dresden 2 and Quad Cities 1 Wheels with Keyway Ultrasonic Indications Dear Mr. Ippolito; Between September,1980 and February,1981, General Electric performed an ultrasonic inspection of the shrunk-en turbine wheels on the low pressure "A", "B" and "C" rotors of the Dresden 2 and Quad Cities 1 turbine-generators. Both mcchines are owned and operated by the Commonwealth Edison Company. Recently, we were requested by Commonwealth Edison to submit to the NRC specific information pertaining to those wheels found to contain keyway ultrasonic indications. The requested information has been prepared and is contained in Tables 1 and 2 on pages 1 and 2 of the attachment "A" hereto. An explanation of the information has also been provided in attachment A.

The data of Tables 1 and 2 are proprietary to General Electric and are so marked. These data are of the type which General Electric's Large Steam Turbine-Generator Division maintains in confidence and withholds from public disclosure. They are properly handled and classified as proprietary by General Electric as indicated by the attached af fidavit.

We hereby request that these sheets and the information contained thereon be withheld from public disclosure in acccedarce with the provisions cf 10 CFR 2.793.

Very truly yours, A7%-

D.P. Timo, Manager Structural Development Engineering Building 41 Room 301 Phone (518) 385-4258 DPT/lar 6

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1 ATTACEMENT 1 GENERAL ELECTRIC CCMPANT i

r Af fidavit of DCMINIC P. TIMO in Suppert <

of Request to Have Certain Technical Data ['

Withheld from Public Disclosure in Accordance with 10 CFR 1.790 DCMIN~C P. TIMO, being duly sworn, depcses and

, i states as follows: ,

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1. I am Manager, Strue". ural Development Engineering, .

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i  ; Large Steam Turbine Generator Division (LST-G) ,  !

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General Electric Company,' and have been delegated l the function of reviewing the information described l

in paragraph 2 which is sought to be withheld and i have been authorited to apply for its withholding.

.b i 2. The following' documents are sought to be withheld: ,

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f i Tables l' and 2 entitled " Turbine Wheel l (Disc) Information for Wheels With Key-  !

. way Ultrasonic Indications" for C:mmon- j

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wealth Edison turbines 170X326 (Dresden

2) and 170X370 (Cuad Cities 1) on pages r 1 and 2 of Attachment A to letter dated ,

May 13, 1981 to Mr. T. A. Ippolito, Chief, Cperating Reactors - Branch 2, OtviJ1cn of Operating Reacters, C. S.

Nuclear Regulatcry Ccamission ,

Washingten, D. C. 20555, frem ,

i Mr. D. P. Timo, Manager, S tructural .

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Derviopment Engineering, Large Steam Turbine-Generator Department, General l Electric Company, Schenectady, New "ork .

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3. General Electric's Large 5 team Turbine-Generator I

Division considers as proprietary any technical, financial or operating data generated by General Electric, whether patentable er not, which is *tsed ,

in its business, which was developed at its own I expense, which is not available to others, which gives to General Electric a competitive advantage over cerpetitors who are not in pcssession of such information, which it has taken steps to maintain as the exclusive property of General Electric, and I s

which the disclosure to its competitors would be detrtmental to General Electric Ccmpany.

4. Scme examples of-types of data which General l Electric's L3T-G Oivisicn censiders to fall within the category of trade secrets or proprietary infor-

- mation, and which it endeavors to maintain exclu-l l'

sivity to , are: i e

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a. Turbine design drawings and data l I i unique to General Electric, i

b. Turbine manuf acturing process instructions utilized in manuf acturing General Electric's I

turbines and known to be unique to General Electric which are of competitive value to General Electric.

c. Materials specificatiens and materials acceptance data prepared by General 2

i Electric's LST-G Division specifically for j i

use in its products and which have charac- 4(

teristics which are of competitive value to, i

General Electric, the loss of exclusivity of which would adversely affect General Electric's LST-G Division's ecmpetitive pcsition.

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d. product data relating to measured and calculated engineering and materials g

parameters of parts and components of i

l L3T-G Divisien's products which convey or i

i from which ene may calculate performance data of General Electric's products in terms of efficiency, reliability and permissible operating conditions. These data are highly proprietary in that, from ,

them a competitor could calculate LST-G j Divisien's key design criteria and a

j tolerances which are related to the relia-bility of the Division's p:cducts, one of

' its mest important ccmpetitive advantages, the losc of which would be highly detri- l i

I mental to General Electric. 1 i

e. Information that discloses a process, method or apparatus where prevention of its use by General Electric's ecmpetiters with-'

out license frem General Electric con-i

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stitutes a ccmpetitive econcmic advantage

] over otner ccmpanies.

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f. Information consisting of supporting data and analyses, including test data, relative to a process, meched or apparatus, the application of which provides a com- ,

petitive econcmic advantage, e.g., by j optimization or improved marketability.  !

g. Information which reveals cost or price ,

information, production capacities, budget l 1evels or commercial strategies of General Electric, its customers or suppliers.

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h. Information which discloses patentable subject matter for which it may be desir-able to obtain patent protection.

, i. Information which General Electric must

, treat as proprietary according to agree-1

? ments With other parties.

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5. In addition to the foregeing material treated as proprietary by General Ziectric's LST-G Divisien, I are internal engineering reports (Data Folders) assigned a classification of 2, 3 or 4 in the l General Electric data classification system and l I

wnich contain any of the foregoing types of data in additien to other data which are not p ro prie ta ry.

Such documents are generated fer internal usage by g

LST-G Division's engineering ccmponents, are not in a form to be released to third parties, and require I

a mixture of proprietary and nonpreprietary infor- l i mation in order to convey the entire picture of an i engineering situation, test procedure or a report i i

on the examination of a customer's apparatus which describes reasons for observed and measured perfo rmance . ,

6. Initially all drawings and internally generated  ;

engineering data within LST-G Divir.*Aa's engineer-ing components are treated as pt:prietary due to the high probability of some of the contents thereof being within one or more of the categories of para- i I

graphs 4 and 5 above. Additionally, such documents :

are generated in such quantity and by engineers andl draf tsmen who of ten are not sophisticated enouch to I l

make a determinatien as to whether or not propri-l etary data is contained therein; it is deemed the ,

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only way to protect LST-G Oivision's : mpetitive

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j position is to treat all such documents and data as I

proprietary until such time as its release to third parties is contemplated. This is a conservative but effective approach. In addition to belag restricted l from third parties, access to such inte rnally 1

j generated documents and data within 13T-G Division is on a need-to-know. basis.

, 7. Before any document or data relating to the productst i

o f General Electric's LST-G Sivision, e.g. , a j l

technical paper for presentation to .

professional }

society, or a trade journal or a product brochure 1si

! to be made available ?.o the general publi:, it is i reviewed by subsection management in the ::mpenent I

in which the action f0r release is initiated to determine that no s'ata which is proprietary to i General Electric it contained therein. It is then l subject to review by section level managament in thei 1

engineering, manufacturing and marketing functions, j f r

or a person desi7nated by such section management, r

, for the purpose of verifying its nonproprietary I

status and the appropriateness of its release. It is also reviewed by legal counsel to determine that its release will not create legal 11ahility for  ;

General Electric C:mpany.

3. When a dccument ecr.taining proprietary informati:n is cenaidered f:r a limited release outside Oeneral Electric on a restricted or limited distribution .

I basis which normally shculd not adversely af fect that l

competitive position cf General Electric, e.g. , to .q i

l' governmental agency, or to a customer, or his agent,;

the appropriate functional manager at unit or I

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l subsection level reviews the appropriateness and business risks'of such releases with his section i manager, and if a positive decision for a limited i i

release of the document is made, the limited release i

is cleared with section level management having l l responsibility in engineering and marketing to f further evaluate the business risks involved. ,

i if the business benefit to be gained by limited r t.

release of the document outweighs the business risk '

of such release by a consensus of concerned manage i i ( '

ment, the requested limited release of such document t

is authorized under the appropriate restrictive i i

! circumstances. Subsequent similar documents for  !

[ which release is desired under similar circumstances i

may thereaf ter be released with the approval of a ' l j subsection level manager, based upon the initial decision and no significant change in f acts.

t Proprietary documents required by vendors for conduct of the business are routinely released by ,

the buyers in LST-G Department Purchasing Section, j but the Purchasing Section routinely requires that .l ,

i all such documents be stamped with restrictiv-. .

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I markings . ,

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Decuments containing proprietary informatien which {

General Electric is obligated to provide to licensees who have accepted an obligation to maintain the sames in confidence are routinely released by the Turbine Licensee Engineer (one individual) with restrictive J

markings.

9. The documents referenced in paragraph 2, above, } ,

I have been evaluated in the light of the criteria '

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and practices set forth above and have been determined as proprietary to I.ST-G Division of General Electric as containing information, the unrestricted release of which would be detrimental to the competitive position of rmeral Electric.

10. The documents referenced in paragraph 2 ;revide i

detailed materials and desigrt information regarding j

shrunk-on wheels of General Electric's nuclear stea::u turbines. T!ris 4 a"ma=*4em is proprietary to General Electric.

NN F. TIMO, bains duly sumarn, deposes and saysL , -

that he has read the foregoing

• affidavit, and the matters stated therein arm true end correct to the best of his  ;

knowledge, information, and belief.

SIGNED at,Schenectady, New York,,this I '~5 day of Crflast , 1981. .

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-- g . (' ,\jf Dr=' ni e P. T1mo _

General Elect =ie CourpanT l STATE CF NDT YORK t

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COUNTY CF SCHINECTADY l

Sworn to and subscribed before me this /T'a day 8 1981 of Wd ,

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